PARTNER COMPLIANCE GUIDELINES - for eToro USA (LLC) All you need to know in one place - eToro Partners

Page created by Douglas Love
 
CONTINUE READING
PARTNER COMPLIANCE GUIDELINES
for eToro USA (LLC)
    All you need to know
    in one place

Marketing Affiliate Rules
Below is a checklist of the main rules that should be followed in any financial promotion on
your affiliate marketing channel:

     Always add the USA LLC Risk Warning:
 1   eToro USA LLC; Virtual currencies are highly
                                                                        f. Withdrawal
                                                                        g. FAQ
     volatile. Your capital is at risk.                                 h. Regulation and License
                                                                        i. Customer Service
     Remember that Etoro offers only real crypto
 2   in the USA and no CFDs
                                                                        j. General Risk Disclosure Use only correct
                                                                        information in your reviews/ articles and
                                                                        always keep them updated as per the list
     Always be fair, clear and avoid misleading
 3   statements.
                                                                        below (not exhaustive) - more information can
                                                                        be found at https://www.etoro.com/en-us/
     Always mention in your affiliate marketing
 4                                                                      Affiliates are only permitted to use eToro’s
     channel which eToro entity you are promoting:
     eToro USA LLC is a registered money services
                                                                   6    official marketing materials which can be found
     business with FinCEN.                                              in the affiliate marketing tools.

                                                                        Any educational materials and/or marketing
 5   Use only correct information in your reviews/
     articles and always keep them updated as
                                                                   7    materials and/or related materials created
     per the list below (not exhaustive) - more                         by the affiliate to be provided to clients (i.e.
     information can be found at                                        banners, videos, newsletters, any significant
     https://www.etoro.com/en-us/                                       changes to the communication channels of the
                                                                        affiliate etc.), through all of the communication
     a. Popular Investors                                               channels, should be reviewed and approved
     b. Our Story (history of eToro)                                    by the Compliance Function/Department of
     c. Team and Investors                                              eToro, prior to dissemination to clients. Any
                                                                        related requests to this matter should be
     d. eToro Copy Systems explanation                                  forwarded to your affiliate account manager.
     e. eToro CopyPortfolios g. Deposits FAQ

eToro USA LLC. © 2019, 221 River St., 9th Floor, Hoboken NJ 07030, NMLS ID: 1769299                                         1
Any new communication channels and any
 8   relevant requests should be immediately
                                                                   AVOID MISLE ADING - ensure that all
                                                                   statements are balanced. Partners can not
     communicated to the Af f iliate Account                       place too much emphasis on the benefits
     Manager and should be pre-approved by the                     associated with a product without also
     Compliance Function/Department of eToro.                      highlighting the relevant risks. Always look
                                                                   for complete, relevant data and add proper
     Affiliates are not allowed to promote eToro                   warnings when using data (see section “How
 9   via sources other than the ones disclosed                     to display risk warnings”)
     and approved by the Compliance Function/
     Department of eToro.                                          U N R E A L I S T I C E X PEC TAT I O N S - t h e
                                                                   information shall not include the name of
                                                                   any competent authority in such a way that
10   Affiliates shall not approach, directly or
     indirectly, any traders and/or potential traders              would indicate or suggest endorsement or
     other than promoting eToro as detailed in                     approval by that authority of the products
     these partner guidelines.                                     or services offered by eToro Entities.

                                                                   KEEP THE TERMINOLOGY AND CONTENT
Leading Compliance Principles                                      UP TO DATE - all the irrelevant information or
                                                                   old terms need to be replaced and updated
                                                                   (i.e., words like: “Guru, copy fund, OpenBook,
                                                                   high leverage and bonuses/promotions).
BE FAIR - do not use misleading headlines                          Please note that all content and marketing
and unfair comparisons. Partners should not                        materials that include BONUS offerings need
hide important information by using small
print. Always make sure that you display risk
                                                                   Please note that all content and marketing materials that include
warnings in a clear and visible way. Never
                                                                   BONUS offerings need to be immediately removed.
promise profits or gains. Do not use any
unqualified or absolute statements unless                          BE CLEAR - about any charges, fees or risks.
they can be proved by including source as to
where the information is taken from.

eToro USA LLC. © 2019, 221 River St., 9th Floor, Hoboken NJ 07030, NMLS ID: 1769299                                                    2
Examples of Misleading Statements                                  Do not use the statements below:

                                                                   a. Become a successful trader!
a. “1 click 60 seconds 85% profit”                                 b. You will make profits!
b. “Gain up to 85% return every 60 seconds”                        c. Make money with the best trader
c. “Start your career as a trader right now”                       d. With eToro, trading is easy
d. “Suggestions are great – it is hard not to win”                 e. Copy the best traders and you will make profits
e. “95% return in a few minutes”
f. “Our Pro signals have been tested to have over                  Do not make any false promises Please note that all
65% daily success rates”                                           content and marketing materials that include BONUS
                                                                   offerings need to be immediately removed.
g. “What can you do in 60 seconds? Copy* and
earn extra money.”                                                 Always disclose the sponsorship depending on if
h. “Learn how to turn market opportunities into                    you are an influencer or an affiliate.
profit”
i. “$10,000 – Get your bonus now.”                                 If posting from abroad, U.S law applies if it’s
                                                                   reasonably foreseeable that the post will affect US
j. “Free”
                                                                   consumers. Foreign laws might also apply.
k. “Investment”, “investing”

Do not incite specific trades eg “Buy bitcoin
before it’s too late”.
Do not use the word “invest”.
Do not suggest the product is “Free”
Use risk warnings where appropriate.
For example, Cryptocurrencies are highly
volatile, be aware of the risks when trading
them.

Do not make any false promises

eToro USA LLC. © 2019, 221 River St., 9th Floor, Hoboken NJ 07030, NMLS ID: 1769299                                      3
How to display risk warning?                                       A few examples of CTA:

Whenever there is a Call to Action (‘CTA’) for                     • Trade now
Cryptos (i.e., Join now, Trade now, Register,                      • Sign up
Open account, Verify etc), a RISK WARNING                          • Join now
IS REQUIRED.                                                       • Buy and Sell
                                                                   • Register Now
The disclaimer should be under/next to View
Website the button (CTA).

It should always be in the language of the                          WARNING: it should be visible and in
website, visible and added to EVERY (CTA).                          the language of the website.
For the small CTA, the disclaimer is:
eToro USA LLC; Virtual currencies are highly
volatile. Your capital is at risk. (always in bold).
For the influencer promoting real crypto, the
disclaimer under CTA is:
eToro USA LLC. This ad promotes copy. Your
capital is at risk.
For mix content ( partner promoting different
eToro entities) the disclaimer should appear
under the US content:
eToro USA LLC does not offer CFDs and makes
no representation and assumes no liability
as to the accuracy or completeness of the
content of this publication, which has been
prepared by our partner utilizing publicly
available non-entity specific information about
eToro. Your capital is at risk

  NOTE: The disclaimers must appear at all times separate from other risk warnings.

eToro USA LLC. © 2019, 221 River St., 9th Floor, Hoboken NJ 07030, NMLS ID: 1769299                        4
Influencer VS Affiliate                                            YOUTUBE

                                                                   While advertising on youtube the following
Influencer                                                         rules should apply:
                                                                   1. At the beginning of the video, the
Definition - Partner with influencers on social                      #sponsorded needs to appear 10 sec as
media who promotes eToro USA LLC                                     per Google’s Ad policies

Purpose - Brand awareness                                            Other options: #ad, #advertisement,
                                                                     Includes Paid promotion
Promoting Platforms - Social media
plat forms such as Facebook, Youtube,                                Please note that the # can be removed
Instagram and more
                                                                   2. If the video is less than or equal to 30 sec,
Who are they? - Celebrities, Bloggers, Media
                                                                     the appropriate time will be 5 seconds at
Personalities, Industry Leaders
                                                                     the beginning and 5 seconds in the end.
Cost - Influencers are generally compensated
with a flat fee (media deal).                                      3. At the end of the video, a disclaimer should
                                                                      be added in order to mention additional
ROI (*return on investment) - Number                                  disclosures that are required under
of new followers, social media engagement,                            applicable laws.
Website Traffic, lead generation

eToro USA LLC. © 2019, 221 River St., 9th Floor, Hoboken NJ 07030, NMLS ID: 1769299                                   5
Affiliate                                                          YOUTUBE

Definition - Business that promote the                             While advertising on youtube the following
brand/content on their Marketing Channel                           rules should apply:
and receive a commission when leads invest                         1. At the beginning of the video, the
in the product/service                                               #eToropartner or #eToroambassador
                                                                     needs to appear 10 sec as per Google’s
Purpose - Lead generation and revenue                                Ad policies.
growth
                                                                     Please note that the # can be removed
Promoting Platforms - Affiliates generally
own websites. They usually operate in the                          2. If the video is less or equal to 30 sec, the
same industry where the audience spends                              appropriate time will be 5 seconds in the
time online                                                          beginning and 5 seconds in the end.
Who are they? - Companies, Publishers or                           3. At the end of the video, a disclaimer should
Blog                                                                  be added in order to mention additional
                                                                      disclosures that are required under
Cost - The standard payment is CPA / Revshare                         applicable laws.
ROI (*return on investment) - Average
order value, Sales volume, Site traffic

eToro USA LLC. © 2019, 221 River St., 9th Floor, Hoboken NJ 07030, NMLS ID: 1769299                                  6
ADDITIONAL RESTRICTIONS

   Please note that if an affiliate cannot amend any of the promotional content of its website in accordance
   with the above rule, the content shall be required to be removed.

   NO BONUSES AND/OR ANY TRADING BENEFIT IS ALLOWED - as eToro USA LLC is regulated by FinCEN
   and cannot offer bonuses whatsoever

   Only target individuals over the age of 18

   Regulatory demands can change often and with no prior notice

   When this occurs, all promotional materials need to be updated immediately. If you want to make any
   changes to eToro promotional materials on your site, you must let us know by contacting your affiliate
   account manager.

   eToro USA LLC cannot be promoted among Binary Options or associated with Binary Options.

   Partner Up!

   In case you need further assistance, do
   not hesitate to contact your direct affiliate
   manager and we will be pleased to assist
   you. We would like to thank you for your
   collaboration and hope to deliver the best
   possible experience for all of our Partners!

eToro USA LLC. © 2019, 221 River St., 9th Floor, Hoboken NJ 07030, NMLS ID: 1769299                            7
You can also read